Document 0gKNy1kX2MO4qgpx24gJj88Vx
Federal Register / Vol. 51, No. 119 / Friday, June.20. 1986 / Rules and Regulations
22617
were not available at the time this study
Overall deaths were significantly (p
was published. Workers were classified less than 0.001) elevated (SMR-167), as
as having worked less than 1 month, 2
were deaths from all cancers (SMR-287j,
months, 3-5 months, 6-11 months, 1
from all "asbestos" diseases (SMRr-396),
year, or 2 or more years. Workers in all from noninfectious lung disease (SMR-
of these exposure categories had
489). and from lung cancer (SMR-541).
excessive mortality from lung cancer.
Colorectal cancer mortality was also
This study demonstrates that workers
significantly (p less than 0.05) increased
with exposures of relatively short
(SMR-185). In addition, 17 deaths from
duration are at excess risk of lung
mesothelioma were observed, a finding
cancer.
of.great significance given the rarity of
This mortality study was updated to include both a longer followup period and exposure estimates. (Seidman, Ex. 261-A). The updated analysis included
ths disease. A strong cumulative doseresponse relationship was evident for both lung cancer mortality and mortality from all "asbestos" diseases.
an additional 593 cases involving deaths
Dement et al. (Exs. 84-036, 84-037)
occurring during the period from 5 to 40 estimated individual cumulative
years after onset of work. To increase
exposures for 768 workers employed at
the comparability of this study with
a chrysotile textile plant during 1930-
others, Seidman re-analyzed the results 1975. Mean exposure levels were
of the earlier study by using death rates estimated for these workers on the basis
for white males from New Jersey to
of 5,952 industrial hygiene samples. The
calculate Standardized Mortality Ratios following exposure categories were
(SMRs). Cumulative exposure to
defined: less than 1,000 f/cc-days, 1,000-
asbestos was estimated for each worker 10:000 f/cc-days and 10,000-10,000 f/cc-
using work history records and exposure days. As explained in the November
measurements taken in 1967,1970, and
proposal. OSHA calculated thut these
1971 from two similar amosite insulation categories of cumulative exposure are production plants. These exposure data roughly equivalent to the following
were collected and reported by NIOSH exposure categories: less than 2.7 f/cc-
(Ex. 2-12). Workers were progressively years; 2.7-27.4 f/cc-years, 27.4-109.0 f/
assigned to the following cumulative
cc-years, 109.6-274 f/cc-years, and
exposure categories during the 35-year greater than 274 f/cc-years. The first
followup period: less than 6.0 f/cc-years, three of these exposure categories fall
6.0- 11.9 f/cc-years, 12.0-24.9 f/cc-years, within at or below the lifetime
25.0- 49.9 f/cc-years, 50.0-99.9 f/cc-years cumulative exposure permitted by the 2-
100.0- 149.9 f/cc-years, 150.0-249.9 f/cc- f/cc standard. Fifteen or more years
years, and 250 or more f/cc-years. The
after the onset of exposure,
use of exposure data from plants other standardized mortality ratios (SMRs) for
. than that from which the cohort was
lung cancer among white males were
derived is appropriate in this study since 140, 279 (p less than 0.05), and 352 (p
the exposure measurements were from less than 0.05) in the first three exposure
"plants of the same company where the categories, respectively, demonstrating
same products were made utilizing the the existence of a dose-response
same machinery, fiber and production
relationship. Dement et al. [Ex. 84-037,
processes" (Ex. 261-A, p. 5). The
p. 432) concluded that: "Based on data
investigators indicated that their
from this study, significantly elevated
exposure estimates may be on the high mortality risks are predicted for lung
side for two reasons: (1) Dustier areas
cancer and for asbestosis at cumulative
tend to be sampled more often than
exposures of 100 fibers/cc-years in the
other areas, and (2) a concerted effort
textile industry." OSHA considers that
was made to have respiratory protection these observations of excess risk from
used by workers in the plant from which low cumulative exposures are well-
the study cohort was taken.
supported because of the careful
Furthermore. Dr. Morton Corn, former
estimation of exposure histories for
Assistant Secretary for OSHA and
members of the cohort in this study.
testifying on the behalf of the.Building
Henderson and Enterline (Ex. 84-048)
and Construction Trades Department,
studied the mortality of 1,075 retired
commented that the Tyler, Texas plant, asbestos production workers. Mean
where some of the exposure data were estimated exposures for the cumulative
obtained, was ", : . one of the most
exposure categories were 62,182. 352,
contaminated asbestos facilities I've
608, and 976 mpef-years. Based on the
ever been in" (Tr. 7/3, p. 67). Therefore, recommended conversion factor of 1:1.4
it is likely that the exposure estimates
for asbestos production (discussed in
were overestimated, leading to an
the November proposal), 62 mpcf-ycars
underestimate of excess risk for workers. is roughly equal to 87 f/cc-years. a
in each of the cumulative exposure
cumulative exposure permitted by the 2
categories.
f/cc standard. An SMR of 197.7 for
respiratory cancer was observed for workers in this cumulative exposure
category. This observed excess
__ .
mortality risk is not as high as that.#33S^^V&:
observed by Dement et al. (Exs. 84-036,
84-037); however, the authors of the Dement et al. study suggested that this
difference may be the result of the fact that Henderson and Enterline studied
retirees, which constitute a select group
of survivors; only 8 of the 35 lung cancer
deaths observed by Dement et al. (Ex.
84-37) occurred among persons 65 or older.
McDonald et al. (Ex. 84-065) studied
the mortality of 11,379 workers exposed
to chrysotile mining and milling. Based
on a conversion factor for these
operations of 1:3 for mpef to f/cc, the
exposure classifications developed by
the authors would correspond to the
following exposure categories: less than
90 f/cc-years, 90-899 f/cc-years. and 900
or more f/cc-years. Although they did
observe an increased incidence of pneumoconiosis (SMRs 298,1081, and
5400, respectively), McDonald et al. (Ex. 84-065) observed less lung cancer risk
for these exposure categories than other investigators (SMRs were 93,118. and
225, respectively). Regarding the
different findings between the studies
by McDonald et al. (Ex. 84-065) and
Dement et al. (Exs. 84-038, 84-037) on lung cancer risk from low exposures.
Dement et al. suggested that differences
in the characteristics of airborne fibers,
as well as the presence of a competing
risk of pneumoconiosis among miners in
the McDonald et al., study, could
account for the differences in lung
cancer mortality reported in these two
studies.
Finkelstein (Ex. 84-240) studied the mortality of 339 men who had been
employed at an Ontario asbestos
cement factory for 9 or more years. Each cohort member was classified as having
accumulated 8-69 f/cc-years, 70-121 f/
cc-years, or 122-420 f/cc-years of
asbestos exposure, during the 18 years
following onset of exposure. Cohort
mortality was analyzed by cumulative
exposure, starting 20 years after onset of
exposure, and was compared to that of
non-exposed Ontario men. Approximate relative risks for lung cancer mortality
for the three exposure categories were
8.5,16.3, and 7.4, respectively. Mesothelioma mortality rates per 1000 man-years were 1.9, 4.9, and 11.9,
respectively, showing a clear dose-
response relationship between asbestos
exposure and mesothelioma.' Finkelstein
suggested severa) explanations for the
unexpected decrease in excess lung
cancer mortality in the highest exposure
category: he argued that statistical
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